In response to the ESMA’s Discussion Paper on the integration of funds’ data, EFAMA concurs with ESMA’s findings that the European asset management industry is subject to multiple and uncoordinated reporting requirements at both the national and European levels. 

To address these reporting duplications and improve data sharing in the spirit of the ‘report once’ principle, EFAMA is advocating for the establishment of an integrated reporting framework for UCITS and AIFs, underpinned by a modular reporting template that includes securities-by-securities data (which is currently separately reported to central banks). Crucially, to avoid future divergence, national authorities should not have the opportunity to introduce additional reporting requirements on top of those imposed by the EU.

Considering the ambitious nature of this project and the costs associated with any reporting change, EFAMA strongly recommends postponing the new UCITS/AIFMD reporting requirements, which are scheduled to take effect in April 2027. ESMA should use this additional time to develop, with the support of a public-private steering group, a well-detailed proposal to achieve this integrated framework. An interim reporting regime would contradict the EU’s simplification agenda, as it would need to be reopened during the following UCITS/AIFMD review in 2029 and revised shortly thereafter.